The U.S. District Court for the Central District of California held that former employees who received an inaccurate summary plan description (SPD) were not entitled to increased retirement benefits as a result of the error. The court ruled that the former employees were not entitled to additional benefits because they failed to prove that they “reasonably relied” on the terms of the faulty SPD. In this case, the employer acquired two companies, merged those companies’ defined benefit plans into the employer’s defined benefit plan, then converted the merged defined benefit plan to a cash balance plan. To harmonize the retirement benefits of the newly acquired employees, the cash balance plan included a transitional formula that incorporated an annuity equivalent offset provision in the retirement benefit calculation. This annuity equivalent offset provision reduced participants’ retirement benefits under the transitional benefit formula. However, the cash balance plan’s SPD did not adequately reference the offset provision. In granting summary judgment in favor of the plan, the court reasoned that, absent a showing of reasonable reliance on the SPD error, the former employees were not entitled to increased retirement benefits. Although some circuit courts do not require a showing of reasonable reliance, the majority of circuit courts do. The Ninth Circuit has not ruled on the necessity of this requirement, but the district court reasoned that providing an additional benefit absent a showing of reasonable reliance would provide a windfall for the former employees and that is a “result abhorred by ERISA.” (Skinner v. Northrop Grumman Retirement Plan B, C.D. Ca., 2010)